the conversational piece in my house this a.m. // food dyes (& non-regulation) linked to behavioral problems according http://j.mp/eTCdrB

“It” is a Washington Post op-ed titled “The rainbow of food dyes in our grocery aisles has a dark side” and is authored by a Columbia University psychiatrist and the executive director of the Center for Science in the Public Interest.

Today’s supermarket is a fun house of hues. Its aisles feature riotously colored processed foods perfectly engineered to appeal to the part of your brain that says “yum”: Technicolor Starburst candy. Polychromatic Froot Loops. A rainbow of flavored juices.

FDA regulates color additives used in the United States. This includes those used in food (and dietary supplements), drugs, cosmetics, and medical devices. These color additives (except coal-tar hair dyes) are subject by law to approval by the agency and must be used only in compliance with the approved uses, specifications, and restrictions…

The authors make two big claims that are designed to plant fear in the heart of the reader:

“Artificial dyes .. are causing behavioral problems and disrupting children’s attention, according to a growing number of scientific studies” and “an FDA staff report released last week concluded that synthetic food colorings do affect some children.”

First, as I noted on my friend’s Facebook page, correlation is not causation. It is the rare (exception) scientific research that proves causation. The authors’ use of a generalization, “growing number of scientific studies”, without specifics about said studies is enough for me to discount the argument.

FDA concludes that a causal relationship between exposure to color additives and hyperactivity in children in the general population has not been established. For certain susceptible children with Attention Deficit/Hyperactivity Disorder and other problem behaviors, however, the data suggest that their condition may be exacerbated by exposure to a number of substances in food, including, but not limited to, synthetic color additives. Findings from relevant clinical trials indicate that the effects on their behavior appear to be due to a unique intolerance to these substances and not to any inherent neurotoxic properties.

Fact Checking The Authors: An Uphill Battle

Given that the WaPo is a mainstream media news site, I am not surprised that there is no link to the FDA staff report or the vaguely referenced “scientific studies”. Primary sources? What primary sources?

Here’s what I could easily find about food additives: nothing here suggests a new report or supports the claim that “the Food and Drug Administration advisory committee will begin a review of research on the behavioral effects of artificial dyes” next week. I don’t doubt that there is a review; however, I am extremely annoyed that a lobbying group has seemingly been given access to information that I, a taxpayer, am not allowed to see.

There was no link to an Advisory Committee on the “food additives” page. In trying to find the poorly referenced Advisory Committee, I learn that there are 49 FDA advisory committees. The Food Advisory Committee is meeting March 30-31 in Maryland “to discuss whether available relevant data demonstrate a link between children’s consumption of synthetic color additives in food and adverse effects on behavior.”

Oh, and about that staff report (emphasis added): “FDA intends to make the complete set of background materials available to the public no later than 2 days before the meeting.” Earth to FDA: if you can provide the material to a lobbying group, you can post it on the website. [For the record, the staff report is available - no post date.]

What the authors of the op-ed failed to note is that the Center for Science in the Public Interest (CSPI) filed a petition that led to this FDA Food Advisory Committee meeting (pdf). The petition is to “ban the use of Yellow 5 and other food dyes” as well as to “require neurotoxicity testing of new food additives and food colors.” In addition, CSPI wants “to correct the information” that FDA “gives to consumers on the impact of these dyes on the behavior of some children.” So, yes, they have a dog in this hunt, a horse in this race (to use my Southern aphorisms). The meeting this week is the direct result of their petition.

Deconstructing The Op-Ed Arguments

I cannot explain why I’m so annoyed, but something about this intellectually dishonest op-ed has acted like fingernails on a chalkboard to my psyche.

Op-Ed

Rebuttal

Today’s supermarket is a fun house of hues. Its aisles feature riotously colored processed foods perfectly engineered to appeal to the part of your brain that says “yum”: Technicolor Starburst candy. Polychromatic Froot Loops. A rainbow of flavored juices.

There are far bigger issues than food dye in the highlighted processed foods.

There is no nutritional value to eating Starburst Candy. One “fun size” package contains 12% of total carboyhdrate intake (2000 calorie diet), most of which is sugar.

To be clear, I know that sugar, alone, has not been linked to hyperactivity (despite anecdotal claims). But sugar consumption has been linked with serious health issues, from heart disease to diabetes.

On Wednesday, following the lead of European regulators, a Food and Drug Administration advisory committee will begin a review of research on the behavioral effects of artificial dyes.

The Center for Science In The Public Interest petitioned FDA to ban food dyes in 2008. The committee reviewed material at its September 2010 meeting.

In a significant turn from the agency’s previous denials that dyes have any influence on children’s behavior, an FDA staff report released last week concluded that synthetic food colorings do affect some children.

From the FDA staff report:
“FDA concludes that a causal relationship between exposure to color additives and hyperactivity in children in the general population has not been established. For certain susceptible children with Attention Deficit/Hyperactivity Disorder and other problem behaviors, however, the data suggest that their condition may be exacerbated by exposure to a number of substances in food, including, but not limited to, synthetic color additives. Findings from relevant clinical trials indicate that the effects on their behavior appear to be due to a unique intolerance to these substances and not to any inherent neurotoxic properties.” ~ FDA FAC Backgrounder, 30-31 March 2011 Meeting (pdf)

Despite those concerns, parents continued to serve up meals and stuff their children’s lunchboxes with more and more processed foods colored with dyes, stoking a five-fold increase in the per-capita production of food dyes over the past 50 years.

What about sugar? The numbers are not as dramatic, but the results are more so. And the results are not questionable.

“Added sugars are food additives that can be recognized by consumers and have been proposed for specific labeling on food and beverage packaging. The results of our study demonstrate that increased added sugars are associated with important cardiovascular disease risk factors, including lower HDL-C levels, higher triglyceride levels, and higher ratios of triglycerides to HDL-C.” (Science 2.0, summary of Journal of the American Medical Association study)

“Consumption of added sugars among US adolescents is positively associated with multiple measures known to increase cardiovascular disease risk” according to a study reported January 10, 2011 in Circulation “For adolescents who were overweight or obese, defined as a body mass index at or above the 85th percentile, added sugars correlated positively with the homeostasis model assessment of insulin resistance.” (Medscape)

In 2004, one of us co-authored an analysis of the best studies of food dyes’ effects on behavior. That analysis found striking evidence that hyperactive children who consumed dyes became significantly more hyperactive than children who got a placebo.

One of the authors is a psychiatrist. He has conducted no primary research on this topic and, according to his Columbia bio, he is not a researcher (he has published two papers) and “[h]e takes particular interest in behavioral finance, the interface between economics and the study of human decision making.”

From the abstract (pdf), emphasis added … “neurobehavioral toxicity may characterize a variety of widely distributed chemicals.” Note that this meta-analysis is of children already diagnosed with a “hyperactive syndrome”. However, the authors of the op-ed repeatedly write in such as way as to mask this fact.

At the same time, the British government funded two studies, each involving almost 300 children. Their results were even more startling: Artificial food dyes (in combination with a common preservative) could make even children with no known behavioral problems hyperactive and inattentive.

There are two weasel phrases in this claim: “could” and “in combination”. When someone carefully choses “could” to make a claim, put on your bullshit detector. Decoded, “could” means that the study does not reveal definitive findings.

And “in combination” means that we don’t know what caused any observed effects.

From the aforementioned FDA staff report (emphasis added):
“In March 2008, the European Food Safety Authority (EFSA) completed an assessment of the Southampton study and concluded that the study provided only limited evidence that the additives had a small effect on the activity and attention of some children; however, the significance of the effects was unclear. For example, it was not known if the small alterations in attention and activity noted in the study would interfere with schoolwork or other intellectual functioning. Further, because mixtures were tested, rather than individual ingredients, the observed effects could not be attributed to any individual additive. EFSA also noted that the effects observed were not consistent for the two age groups or for the two mixtures tested in the study. In 2009, EFSA re-evaluated the safety of the six color additives used in the Southampton study and concluded that the available scientific evidence does not substantiate a link between the color additives and behavioral effects.” ~ FDA FAC Backgrounder, 30-31 March 2011 Meeting (pdf) (emphasis added)

Next, the European Parliament required that foods containing those chemicals bear a label warning that the dyes “may have an adverse effect on activity and attention in children.”

From the FDA staff report”
“In July 2010 the European Union (EU) began requiring warning labels on foods that contain any of the color additives tested in the Southampton study. The U.S has expressed concerns to the World Trade Organization that the warning label is not based on adequate scientific evidence. In the U.S, any food containing color additives that FDA certifies for food use, such as FD&C Red No. 40 and FD&C Yellow No. 5 (two of the color additives tested in the Southampton study), must be declared by name as ingredients on the food label.” ~ FDA FAC Backgrounder, 30-31 March 2011 Meeting (pdf)

Beyond the behavioral problems and cancer risks, the greatest hazard that dyes pose for children may also be the most obvious: They draw kids away from nutritious foods and toward brightly colored processed products that are high in calories but low in nutrients, such as fruit-flavored drinks and snack foods.

The last time I checked, pre-kindergarten and elementary-aged children were not going to the grocery store, checkbook or debit card in hand, and buying tonight’s dinner or tomorrow’s breakfast.

Does America have health problems associated with highly processed foods? I think that answer is a resounding yes (so does Jamie Oliver), but that doesn’t mean that I think the solution is banning food dyes.

Figure out a way to shame the food processing industry into reducing its use of sugar and sodium. Figure out a way to do broad educational outreach like Oliver’s. Figure out a way to internalize the social costs of poor nutritional choices. Focus attention in a cost-benefit analytical way: where the smallest actions can yield the greatest results.

Artificial colorings are explicitly meant to manipulate consumers’ perceptions. Manufacturers tout research showing that redness enhances the impression of sweetness, and that in tests with beverages and sherbets, the color of the product did more to influence consumers’ perception of the flavor than the flavor itself.

For repeat purchases, maybe. See my note above about who actually wields the checkbook.

And hey, if redness enhances the impression of sweetness, use that redness to offset the actual amount of sugar in the food. That would be a net gain for health, for most people not just hyperactive children.

Today, Britons enjoy all the colorful foods they have come to expect without many of the health risks they learned to avoid. Here, we get the same foods — but until the FDA bans synthetic dyes, we get them with a side order of dangerous and unnecessary chemicals.

Conclusion fails for lack of supporting evidence. I have not seen data to demonstrate the cost of shifting to “natural” dyes, either in the cost of the ingredient or in the cost of reformulation. Yes, “natural” is probably better. But in this case, in my opinion it masks a far greater health issue: sugar.